EU/UK GDPR Privacy Notice
Table of Contents
Introduction
This EU/UK GDPR Privacy Notice supplements our main Privacy Policy and provides specific information required under the European Union General Data Protection Regulation (EU GDPR) and the United Kingdom General Data Protection Regulation (UK GDPR) for individuals located in the European Economic Area (EEA) or United Kingdom.
This Notice should be read together with our main Privacy Policy, which contains comprehensive information about how we collect, use, and protect your personal information. This Notice provides additional details specific to GDPR requirements, including your data subject rights and our legal bases for processing.
Scope: This Notice applies to personal data of individuals located in the EEA or UK that we process in connection with our services, regardless of where Becoming Alpha, Inc. is located.
Data Controller Information
Data Controller: Becoming Alpha, Inc., a Delaware corporation headquartered at 8000 Avalon Boulevard, Suite 100, Alpharetta, GA 30009, USA, is the data controller for personal data processed in connection with our services.
Data Protection Officer: We have appointed a data protection officer (DPO) to oversee our data protection practices. You can contact our DPO at:
Email: privacy@becomingalpha.world
Subject Line: "Data Protection Officer"
Legal Bases for Processing
Under GDPR, we must have a legal basis for processing your personal data. We process your personal data based on the following legal bases:
1. Performance of a Contract
We process your personal data when it is necessary to perform our contractual obligations to you, such as:
- Providing you with access to our platform and services
- Processing transactions and payments
- Communicating with you about your account and services
- Verifying your identity (KYC/KYB) as required by law and our Terms of Service
2. Compliance with Legal Obligations
We process your personal data when required to comply with applicable laws and regulations, including:
- Anti-money laundering (AML) and know-your-customer (KYC) requirements
- Financial regulations and reporting obligations
- Tax reporting and compliance requirements
- Sanctions screening and compliance
3. Legitimate Interests
We process your personal data based on our legitimate interests, balanced against your rights and interests, including:
- Fraud prevention and security
- Platform security and abuse prevention
- Improving our services and platform functionality
- Marketing and communications (where permitted and you have not opted out)
- Business operations and analytics
You have the right to object to processing based on legitimate interests. For more information, see "Your Data Subject Rights" below.
4. Consent
We process certain personal data based on your consent, such as:
- Marketing communications (where required by law)
- Non-essential cookies and tracking technologies
- Certain optional data processing activities
You can withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
5. Vital Interests
In rare circumstances, we may process personal data to protect your or another person's vital interests, such as in emergency situations.
Categories of Personal Data
We process the following categories of personal data, as defined under GDPR:
Identity Data
- Name, date of birth, government-issued ID numbers, ID documents
- Business information (for business accounts)
Contact Data
- Email address, phone number, mailing address
Financial Data
- Payment information, transaction history, wallet addresses
- Bank account details (if applicable)
Technical Data
- IP address, device information, browser type, operating system
- Usage data, log files, cookies and similar technologies
Profile Data
- Account preferences, username, profile information
Marketing and Communications Data
- Marketing preferences, communication preferences
Special Category Data
We generally do not process special category personal data (e.g., data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data) unless required by law or with your explicit consent.
Purposes of Processing
We process your personal data for the following purposes:
Service Delivery
- Providing access to our platform and services
- Processing transactions and payments
- Managing your account
Legal and Regulatory Compliance
- Identity verification (KYC/KYB)
- Anti-money laundering (AML) compliance
- Sanctions screening
- Tax reporting and compliance
Security and Fraud Prevention
- Detecting and preventing fraud, abuse, and security threats
- Maintaining platform security
- Investigating suspicious activity
Service Improvement
- Analyzing usage patterns and platform performance
- Developing new features and services
- Improving user experience
Communications
- Responding to your inquiries and support requests
- Sending service-related communications
- Marketing communications (with your consent or where permitted by law)
Your Data Subject Rights
Under GDPR, you have the following rights regarding your personal data:
1. Right of Access
You have the right to access and receive a copy of your personal data that we hold. You can request access by contacting us at privacy@becomingalpha.world.
2. Right to Rectification
You have the right to have inaccurate personal data corrected and incomplete data completed. You can update some information directly through your account settings, or contact us for assistance.
3. Right to Erasure ("Right to Be Forgotten")
You have the right to request deletion of your personal data in certain circumstances, such as when:
- The data is no longer necessary for the purposes for which it was collected
- You withdraw consent and there is no other legal basis for processing
- The data has been unlawfully processed
However, we may be required to retain certain data to comply with legal obligations (e.g., AML/KYC retention requirements).
4. Right to Restrict Processing
You have the right to restrict processing of your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.
5. Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
6. Right to Object
You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests.
7. Right to Withdraw Consent
Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
8. Right Not to Be Subject to Automated Decision-Making
You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect you. We generally do not make such decisions, but if we do, we will inform you and provide an opportunity to contest the decision.
Exercising Your Rights
To exercise your rights, please contact us at privacy@becomingalpha.world. We may need to verify your identity before processing your request. We will respond to your request within one month (may be extended to two months for complex requests).
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
- Compliance with legal obligations (e.g., AML/KYC retention requirements of 5+ years)
- Resolution of disputes and enforcement of agreements
- Legitimate business interests (e.g., fraud prevention, security)
For detailed information about our data retention practices, please see our main Privacy Policy.
International Data Transfers
As a U.S.-based company, your personal data may be transferred to and processed in the United States and other countries outside the EEA/UK.
Safeguards: We ensure that international transfers are subject to appropriate safeguards, including:
- Standard Contractual Clauses (SCCs): We use EU-approved Standard Contractual Clauses for transfers to processors and controllers outside the EEA/UK
- Adequacy Decisions: We rely on adequacy decisions where applicable
- Other Safeguards: We implement additional technical and organizational safeguards to protect your data
For more information about our international transfer safeguards, please contact us at privacy@becomingalpha.world.
Contact Information
For questions about this EU/UK GDPR Privacy Notice or to exercise your data subject rights:
Company: Becoming Alpha, Inc. (a Delaware corporation)
Address: 8000 Avalon Boulevard, Suite 100, Alpharetta, GA 30009, USA
Data Protection Officer / Privacy Email: privacy@becomingalpha.world
General Support: support@becomingalpha.world
For comprehensive information about our data processing practices, please see our main Privacy Policy.
For more contact options and additional ways to reach us, please visit our Contact page.